Quick answer
Influencer gifting means sending free products to creators in the hope that they post about them, with no fee and usually no required post. Under the FTC Endorsement Guides, a free product counts as a material connection regardless of whether the advertiser requires an endorsement in return, so a creator who posts about it should disclose the gift. The brand should also tell creators how to disclose and monitor the resulting tagged posts.
Nation, an AI store builder, publishes this page. It is pre-launch, with a waitlist on withnation.ai, and it is not an influencer platform or an agency. See where Nation fits.
What influencer gifting and product seeding are
Influencer gifting is sending a free product to a creator so they can try it, with the hope that they share it with their audience. Product seeding is the same idea run as a program: a brand sends products to a planned list of creators at the same time, often around a launch, and tracks who posts.
Gifting differs from a paid partnership in one way that matters for planning. A paid creator agrees to make content on a schedule. A gifted creator usually agrees to nothing, so some packages will never appear online. Brands accept that because the cost per creator is the product and the postage.
Free does not mean outside the rules. The FTC's Endorsement Guides list free or discounted products (including products unrelated to the endorsed product) as a material connection between a brand and an endorser, regardless of whether the advertiser requires an endorsement in return. A creator who mentions a gifted product should disclose that they got it free, and the brand has duties of its own, covered further down this page.
An influencer gifting strategy in six steps
This is a workable order for a small brand. The FTC steps sit inside the plan because the brand carries its own responsibility for what gifted creators post.
Set one goal
Pick what the program is for: content you can reuse with permission, reviews ahead of a launch, or reaching a new audience. The goal decides which creators you pick and what you track.
Build a creator list
Find creators who already post about your category and whose audience matches your buyers. Note their handle, country, typical post format and how their followers respond in comments.
Ask before you ship
Send a short message offering the product and asking for a shipping address. Asking first cuts wasted packages and gives you a written record that you contacted them.
Send a brief with the package
Include what the product is, any claims they may and may not make, how to disclose the gift, and the handle to tag. FTC staff say a brand that sends only a free product should ask creators to disclose the gift, tell them how, and ask them to tag the brand.
Ship and log
Ship with tracking, and log the date sent, the tracking number, the product and its cost against each creator.
Track and follow up
Check tagged posts, record what each creator posted, and check that each post carries a clear disclosure. Ask for a fix if one is missing.
How to choose creators for product seeding
Follower count is the least useful filter for a small brand. A creator with a small, engaged audience in your exact niche can do more for a new product than a large general account, and may be more likely to reply to a direct message.
Look at the last few weeks of each creator's posts before you add them to the list.
- Fit: they already post about products like yours, in a style your buyers would recognise.
- Audience: the comments come from people who look like your customers, and the creator is based where you can ship.
- Disclosure habits: they already label sponsored or gifted posts clearly. A creator who never discloses is a risk for your brand too.
- Claims: for skincare, supplements and other health products, check that they do not make medical claims. The FTC notes that a network selling health products may require more supervision than one promoting a fashion line.
- Overlap: avoid sending to several creators with the same audience in the same week, or the posts compete with each other.
Shipping and what a gifting program costs
The cost of influencer gifting is the product at cost, packaging, postage, and your time. There is no creator fee, but the time to find, message and follow up with each creator is real, so plan the list size around the hours you have.
Example: a candle brand sends 20 creators one candle each. Assume a product cost of $9, $3 of packaging and an insert card, and $8 of postage per package. The program costs 20 × $20 = $400 before your time. If 8 creators post, the cost per post is $50. These figures are assumptions for the example, not averages.
A few shipping habits save money and confusion.
- Use tracked shipping so you know a package arrived before you follow up.
- Put the brief on a printed card in the box as well as in your message: the product name, the handle to tag, and the disclosure wording you want.
- Ship to creators abroad only if you can deliver to them and they reach your buyers. The FTC's staff guidance says U.S. law applies if it’s reasonably foreseeable that the post will affect U.S. consumers.
- Keep a cost record per creator so you can compare gifting with paid posts or ads later.
FTC disclosure rules when the product is free
The FTC's Guides Concerning Use of Endorsements and Testimonials in Advertising are 16 CFR Part 255 in the Code of Federal Regulations, and were revised in 2023. They apply to influencer gifting because a free product is a material connection. FTC staff guidance for influencers says to disclose if you got anything of value to mention a product, and to make a disclosure even if you weren’t asked to mention that product.
The duty sits on both sides. The Guides say that An advertiser may be liable for a deceptive endorsement even when the endorser is not liable. For brands that send only free products, FTC staff say training material alone is not enough: It’s important, but insufficient. The table sets out what each side should do.
This page is general information, not legal advice. State consumer protection laws and the platforms' own branded content rules can add to the federal rules, and rules vary by state. For a full walk-through of the Endorsement Guides, see the FTC influencer guidelines guide linked below.
What a good gifting disclosure looks like
The FTC does not require exact wording, but its staff guidance gives examples. A plain line such as "Thanks to Acme brand for the free product" is often enough when it is hard to miss. Terms like “advertisement,” “ad,” and “sponsored.” also work.
Put the disclosure wording in your brief so creators do not have to guess. These are the placement points from the FTC's Disclosures 101 for Social Media Influencers.
- Place the disclosure with the endorsement message itself. Disclosures are likely to be missed if they appear only on a profile page, at the end of posts or videos, or anywhere that requires a person to click MORE.
- Don’t mix your disclosure into a group of hashtags or links.
- For video, the disclosure belongs in the video and not just in the description.
- In a live stream, the disclosure should be repeated periodically.
- Avoid vague terms such as “sp,” “spon,” or “collab,” which many viewers will not understand.
- Don’t assume that a platform’s disclosure tool is good enough. A creator can use the built-in paid partnership label and still add their own line.
How to track a gifting program
Tracking answers two questions: did the gift turn into content, and did that content lead to sales. A spreadsheet is enough for a first program. Log one row per creator with these columns.
- Creator handle, platform and the date you first contacted them.
- Product sent, its cost, the ship date and the tracking number.
- Whether they posted, a link to each post, and the date.
- Whether each post has a clear disclosure, and the date you asked for a fix if not.
- A unique discount code or tagged link per creator, and the orders it brought in.
- Whether you have written permission to reuse the content, and where.
Check tagged posts at least weekly while a program is running. Stories and other short-lived posts disappear, so screenshot them when they appear. If checking every post is more than you can manage, FTC staff suggest you switch to pre-approval of posts. Keep the log after the program ends. A creator you keep sending products to has an ongoing relationship with your brand, and FTC staff tell creators in that position that you should still disclose that relationship even if you buy the brand’s product yourself.
Where Nation fits
Nation
Category: an AI store builder
Nation says one description of what you make builds the store, then agents handle orders, customers and delivery and run ads, content and social posts, with you approving the work. It is not an influencer platform, and this page does not recommend any gifting tool.
Limits today
- Status: pre-launch, with a waitlist on withnation.ai.
- Pricing and fees: not announced yet.
- Shopper marketplace: no shopper marketplace has been announced.
- Track record: no independent reviews or public stores yet.
Nation publishes this page. The disclosure rules come from the FTC's own pages, not from Nation.
Describe what you makeQuestions about influencer gifting
What is influencer gifting?
Influencer gifting is sending a free product to a creator so they can try it and, if they like it, post about it. There is usually no fee and no required post. Under the FTC Endorsement Guides the free product is still a material connection, so a creator who posts about it should disclose the gift.
What is product seeding?
Product seeding is influencer gifting run as a planned program: a brand sends the same product to a list of chosen creators at once, often before or at a launch, then tracks who posts. Like any gifting, it creates a material connection, so posts about the seeded product need a clear disclosure.
Do influencers have to disclose gifted products?
Influencers have to disclose gifted products when they post about them. FTC staff guidance says to disclose if you got anything of value to mention a product, and to make a disclosure even if you weren’t asked to mention that product. The disclosure should sit with the post itself, not only in a bio or a block of hashtags.
Is the brand responsible if a gifted influencer does not disclose?
The brand shares responsibility when a gifted influencer does not disclose. The FTC Endorsement Guides say An advertiser may be liable for a deceptive endorsement even when the endorser is not liable. Brands should tell creators how to disclose, ask them to tag the brand, monitor the resulting tagged posts, and ask for a fix when a disclosure is missing.
Does a small or cheap gift need to be disclosed?
A small gift is still something of value, and FTC staff say it can be hard to judge whether a small gift would change how people weigh a post. Their guidance concludes: It’s always safer to disclose that information. Brands can simply ask every gifted creator to disclose.
What should an influencer gifting strategy include?
An influencer gifting strategy should include one goal, a creator list chosen for fit rather than follower count, a message asking before you ship, a brief with disclosure wording and permitted claims, tracked shipping, and a log of posts, disclosures and sales per creator. Review the log before planning the next round.